Tribunal Resolves Tax Disputes: Non-Resident Commission, Section 14A Interpretation, and CSR Expense Challenges Examined Comprehensively

ITAT adjudicated multiple tax issues involving TDS, section 14A, and CSR expenses. On TDS u/s 195, the tribunal held that commission paid to non-resident for services rendered outside India is not chargeable to tax, thus TDS deduction was not mandatory. Regarding section 14A, the tribunal found no exempt income was generated, rendering disallowance impermissible. For CSR expenses, the tribunal upheld the disallowance under section 37(1) as the assessee failed to substantiate that expenses were incurred exclusively for business purposes. The tribunal deleted TDS and section 14A additions while maintaining CSR expense disallowance. .....

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